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MACRA and the Axon Registry: What You Need to Know Lyell K. Jones Jr. MD, FAAN Vice Chair, AAN Registry Committee Associate Professor of Neurology, Mayo Clinic September 8, 2016 ©2015 American Academy of Neurology
Goals • By the end of this session, we want you to be able to explain to a colleague: The essential aspects of MACRA and its effect on CMS payment systems Differences between the two major components of MACRA: the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APM) Interactions between the MACRA and the Axon Registry
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Background: Health Care Costs
Projections of National Health Care Expenditures and Share of GDP, 2013-2023 ©2015 American Academy of Neurology
Source: Kaiser Family Foundation Slide 3
Background: Health Care Costs
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CMS, 2015: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Factsheets/2015-Fact-sheets-items/2015-01-26-3.html Accessed 2/5/15
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Background: Current CMS Programs • Physician Quality Reporting System (PQRS) Providers who report approved quality measures avoid penalties (up to -2% in 2017) CMS will be moving to performance based adjustment
• Value-Based Payment Modifier (VBPM) Providers are scored on PQRS performance and resource use (cost) to receive bonuses or penalties (-4% to +4%)
• Meaningful Use (MU), or EHR Incentive Payment Program Has transitioned from bonuses for attestation to penalties for failing to attest (-4% in 2017) ©2015 American Academy of Neurology
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What is MACRA? • The Medicare Access and CHIP
Reauthorization Act of 2015 (MACRA) • Passed with wide bipartisan and bicameral support House vote: 392-37 Senate vote: 92-8
• Signed into law April 16, 2015 • Proposed rule released April 2016 ©2015 American Academy of Neurology
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Medicare Payment Modernization • Permanent repeal of the SGR • MACRA implements a completely new payment structure
Volume
Value
• Rulemaking will be critical to implementation ©2015 American Academy of Neurology
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Quality Payment Program
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MIPS Exclusions
First year of Medicare Part B Participation
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Below low volume threshold for patients seen/ Medicare allowable charges
Qualifying participant in an approved advanced Alternative Payment Model (APM) Slide 9
MIPS Performance Categories • Quality • Resource Use • Advancing Care Information • Clinical Practice Improvement Activities
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MIPS Performance Categories Quality (50%) Resource Use (10%)
Advancing Care Information (25%) Clinical Practice Improvement Activities (15%) ©2015 American Academy of Neurology
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MIPS Performance Categories • Quality (50%) Will closely resemble PQRS Measures will be selected from multiple domains: –Clinical care –Safety –Care coordination –Patient and caregiver experience –Population health and prevention
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MIPS Performance Categories • Quality (50%) Certain measure types will be given priority for inclusion: –Outcomes –Patient experience (such as patient reported outcomes or PROs) –Care coordination –Appropriate resource use
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MIPS Performance Categories • Resource Use (10%) This will be similar to the Value-based Payment Modifier (VBPM) New “classification codes” will be used: –Care episode groups: likely will be used to identify episodes in episode-based payment models –Patient condition groups: likely will be used for group assignments with condition-based payment –Patient relationship categories: likely will be used to define provider attribution of patient outcomes ©2015 American Academy of Neurology
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MIPS Performance Categories • Advancing Care Information (ACI, formerly Meaningful Use or MU) (25%) Will generally align with existing MU requirements Inconsistencies between current programs (e.g., PQRS and MU) will be eliminated Approved measures (in the Quality category) will automatically satisfy the MU quality measure reporting requirements
©2015 American Academy of Neurology
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MIPS Performance Categories • Clinical Practice Improvement Activities (CPIAs) (15%) This is new for CMS, but will feel similar to practice improvement activities in other parts of our practice Approved CPIAs will likely include: –Expanded practice access –Population health management –Care coordination –Beneficiary engagement –Patient safety and practice assessment –Participation in an APM QCDR (registry) participation will positively impact score ©2015 American Academy of Neurology
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MIPS Risk Corridor 10.00%
5.00%
0.00% 2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
-5.00%
-10.00%
Combined PQRS, MU, VBPM penalties -15.00% Annual Update
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Max. Penalty
Bonus Potential Slide 17
Alternative Payment Models • Providers that receive significant revenue from qualifying APMs are exempt from MIPS • Eligible for 5% bonus 2019-2024 • Qualifying APMs: Use certified EMR technology Employ quality measures similar to MIPS Must be risk-bearing
• Model criteria to be further defined by CMS ©2015 American Academy of Neurology
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Alternative Payment Models • Current examples of APMs: Accountable care organizations (ACOs) Patient-centered medical homes (PCMHs) “Bundled” payments/episode-based payments
• Advanced APMs described in proposed rule are very narrowly defined Flexibility and specialty-relevant models will be important to encourage neurologist participation The AAN is actively developing neurology-relevant APMs ©2015 American Academy of Neurology
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Alternative Payment Models • A Technical Advisory Committee (PTAC) has been formed to advise CMS on development of new APMs 11 members, 7 physicians
• New APMs may be submitted on an ongoing basis • CMS is tasked with developing APMs targeted to: Specialty practices Smaller practices Risk-based models
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Overall Payment Updates 2015-2018 2019
2020
2021
20222024
2025
2026+
0.5%
0%
0%
0%
0%
MIPS: 0.25% APM: 0.75%
MIPS PQRS, MU, -4% to Adjustment and VBPM +4%* Factor penalties in effect (4.5% to 10%+)
-5% to +5%*
-7% to +7%*
-9% to +9%*
-9% to +9%
-9% to +9%
APM Bonus
5%
5%
5%
5%
% Medicare Revenue from APM
25%
25%
50%
50-75%
75%
75%
Conversion Factor Update
©2015 American Academy of Neurology
0.5%
*additional bonus for top performers NOT included
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MACRA: Specialities and Subspecialties • While the proposed rule reduced the number of reported quality measures from 9 to 6, there may be few relevant options in a subspecialty practice • Advanced APMs are narrowly defined, with unresolved barriers for specialty practices • Risk adjustment in the proposed rule does not take into account subspecialty patient populations
©2015 American Academy of Neurology
How is AAN preparing for MACRA? • The AAN has been very active in the regulatory
advocacy phase, urging CMS to consider neurologists and their patients in the rulemaking process • AAN staff and volunteers are actively working to develop new payment models that better serve neurologists • Using numerous channels (trained speakers, AAN.com, online videos, the Annual Meeting, etc), the AAN is working to educate neurologists on the urgency of approaching payment changes ©2015 American Academy of Neurology
Axon Registry Participation TM
• Will seamlessly report Quality data and ACI attestation in MIPS • Will positively impact score on CPIA component of MIPS • Will give practices access practice trend data and identify potential areas for improvement • Go to www.aan.com/practice/axon-registry for more information ©2015 American Academy of Neurology
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MACRA and the Axon Registry • The rule proposes QCDRs act as intermediaries on behalf of clinicians and submit data for the Quality, CPIA, and ACI categories: Quality - Means for quality reporting component Clinical practice improvement activities – Component of several CPIAs and as a means to attest to participation Advancing care Information- Means for attestation in ACI component
• In the future, align MIPS/Axon measures and further clarify CPIAs ©2015 American Academy of Neurology
MACRA and the Axon Registry • Concerns with the proposed rule: Little detail in proposed rule on requirements for QCDRs No guidance for vendors or QCDRs As CMS further clarifies, AAN will assess AAN’s potential financial impact of providing service and vendor capability to develop the technology
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What do you need to do now? • If you haven’t reported on meaningful use (MU), start now • If you haven’t reported PQRS measures, start now • If you have done PQRS, become familiar with your QRUR reports to identify areas for improvement
©2015 American Academy of Neurology
MACRA: Take Away Points • MACRA signals the transition to value-based payment systems • Many details have yet to be clarified in the final MACRA rulemaking • The ideal MACRA participation pathway for any one practice will depend on a number of factors • Axon will be an important tool for neurologists in the MACRA era ©2015 American Academy of Neurology
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Questions?
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Thank you!
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